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The article examines the impact of the U.S. Supreme Court's decision in Wal-Mart Stores Inc. v. Dukes which concerns certification of class actions under Federal Rule of Civil Procedure 23. It points out that often overlooked is the portion of the decision holding that the class claims for monetary relief could not be certified under Rule 23 (b) (2). It identifies the requirements of Rule 23 which must be satisfied.